On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more
6/19/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Foreign Corporations ,
Foreign Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Proposed Legislation ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
Taxation ,
Trump Administration ,
U.S. Treasury ,
Withholding Tax
On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
6/17/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Digital Services Tax ,
FDAP ,
FIRPTA ,
Foreign Governments ,
Foreign Investment ,
Foreign Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Private Funds ,
Proposed Legislation ,
Tax Rates ,
Taxation ,
U.S. Treasury ,
Withholding Tax
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
1/10/2023
/ C-Corporation ,
FIRPTA ,
Foreign Governments ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Pension Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
S-Corporation ,
Tax Exemptions ,
U.S. Treasury
On August 7, after weeks of negotiations, the Senate voted 51-50 to pass a budget reconciliation package known as the Inflation Reduction Act (the “Bill”), introduced by Senators Joe Manchin (D‑WV) and Chuck Schumer (D‑NY) in...more
8/11/2022
/ Affordable Care Act ,
Alternative Minimum Tax ,
Carbon Capture and Sequestration ,
Clean Energy ,
Corporate Taxes ,
Energy Tax Incentives ,
Excise Tax ,
International Trade Commission (ITC) ,
IRS ,
Manufacturing Facilities ,
Offshore Wind ,
Tax Credits
As widely reported, on July 27, 2022 Democratic Majority Leader Senator Chuck Schumer and Senator Joe Manchin (D-W.Va) agreed to a reconciliation bill package titled the Inflation Reduction Act of 2022. The bill contains...more
8/2/2022
/ Capital Gains ,
Carried Interest ,
Fund of Funds ,
Holding Periods ,
IRS ,
Legislative Agendas ,
Long-Term Investment Funds ,
Proposed Legislation ,
Regulatory Authority ,
S-Corporation ,
U.S. Treasury